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LeadingAge NY Gets More Clarification Regarding Person-Centered Care Template in ACF and Assisted Living Settings

LeadingAge NY spoke with the Department of Health (DOH) on July 27th regarding the guidance issued on July 14th detailing requirements related to the federal Home and Community-Based Services (HCBS) Settings Rule for adult care facilities (ACFs) and assisted living (AL) settings. We were able to obtain some important clarifications on the use of the Person-Centered Care Template in ACF/AL settings. DOH confirmed that use of the template is not a requirement if the individual does not receive Medicaid-funded HCBS. The Department committed to providing us with a list of HCBS that are covered under the federal rule for the purposes of this requirement. Below is our understanding regarding the use of the template for the various categories of providers.


DOH clarified that, at this time, the Medicaid assisted living program (ALP) is responsible for the completion of the Person-Centered Care Template. DOH is in the process of developing a plan to procure a third party to provide conflict-free case management to ALP residents, however, to comply with the conflict of interest aspect of the federal rule. Once that party is identified and operational, that entity will be responsible for completing the template in coordination with the ALP. By way of background, LeadingAge NY has been actively engaged with the Department on the conflict-free case management issue for months, to help ensure that this requirement is least disruptive to ALPs and the people they serve. Click here and here for the most recent information on this issue.

Non-ALP ACFs and ALRs

For an ACF or assisted living residence (ALR) provider (not licensed as an ALP) serving Medicaid-eligible people who are receiving Medicaid-covered HCBS, the template will most likely be completed by the individual’s Managed Care Plan, Managed Long Term Care (MLTC) Plan, or the Local Department of Social Services (LDSS). This entity should be sharing the Person-Centered Care Plan with the ACF or ALR, and the ACF/ALR should communicate any modifications to the service plan and otherwise share information for the purposes of coordination.


DOH also indicated that a provider could choose not to use the template, but rather document the information in another way. The key would be ensuring that all components of the plan were addressed in that alternative mechanism. LeadingAge NY is working with other stakeholders to explore incorporating the Person-Centered Care Template elements into the model Individualized Service Plan (ISP) for ALRs.

Additional Information

Click here for background on the HCBS Settings Rule and person-centered planning requirements.

As a reminder, DOH will be providing a webinar on Aug. 17th at 2 p.m. regarding this guidance; be sure to register.

LeadingAge NY has sent DOH numerous questions and suggestions to be addressed, ideally in the August webinar. We encourage members to review the Dear Administrator Letter (DAL) and template closely and provide us with any questions you may have. We will compile them and seek answers from DOH. You may also submit questions directly to DOH at acfhcbs@health.ny.gov; however, we encourage you to copy LeadingAge NY on those questions.

Members are also reminded that there are some aspects of the rule that all ACFs must adhere to. These requirements are outlined in the DAL issued on July 14th and will be evident in new regulations yet to be finalized.

Contact: Diane Darbyshire, ddarbyshire@leadingageny.org, 518-867-8828